Following an extensive consultation with members of the Green Infrastructure Partnership[1], a response to the draft NPPF 2018 was published and sent to the Ministry of Housing, Communities and Local Government (MHCLG)[2]. This forms a key output of my Natural Environment Research Council Knowledge Exchange fellowship[3], which seeks to improve the way that nature is mainstreamed in planning policy and decision making. As the new NPPF 2018 is expected to be published tomorrow here are the key aspirations from that document.

First and foremost, nature is not a bolt-on or secondary issue to economic development and housing. It is the bedrock upon which a successful economic development strategy and delivery can be built and thus should be built in from the outset. However, the silos and institutional myopia within national and local government are hindering more effective planning policy and delivery. Current normal[4] weather in the UK (based on extreme wet/dry/windy/hot/cold conditions) highlights this interdependence quite graphically.

That the NPPF formally adopts the United Nations sustainable development goals as the primary purpose of the planning system, set within a wider placemaking vision[5]. Currently the sustainable definition is elusive and unclear in the NPPF. There is currently a lack of a vision in the document and Placemaking offers a powerful and positive ideal that embeds quality, citizen engagement and resilience which acts as bedrock to build policies. Furthermore, the adoption of UN goals allows their indicators to be used to monitor progress.

That the proposed downgrading of local plans to only being voluntary is changed requiring all local planning authorities to prepare a statutory local plan to help deliver the placemaking agenda. The key issues associated with development of place and place based approaches are achieved through a mandatory local plan. It absence will lead to a void.

That the NPPF formally adopts and strengthen the key provisions in the HM Government 25 Year Environment plan[6] to fulfil its claim to be the greenest government ever. At present the NPPF makes only passing reference in paragraphs and leaves areas of huge uncertainty over the strength of some nature based policies in plans and decisions. Specifically:

A more explicit concern for social justice in development to reflect concerns over air pollution and health; applying both to new development and also retrofit.

A more robust statement of common ground to necessarily include nature based solutions, climate change biodiversity and water management as mandatory strategic issues rather than allowing local authorities to choose the strategic issues. Currently housing dominates the previous duty to cooperate.

To champion a natural capital approach rather than simply to recognise its value. Natural capital is the building blocks for a resilient economy if it is managed properly through the benefit flows of ecosystem services and through the delivery mechanisms such as green infrastructure.

To have a stronger policy requirement for climate change considerations; both as a strategic issue but as a requirement for all developments. This requires new building regulations associated with greywater/rain capture systems , living walls and SuDS. This should be in new builds but also part of a large scale retrofit agenda.

Both net biodiversity and net environment gains should become mandatory rather than aspirational.

The placemaking agenda requires a more integrated approach to planning issues. The need to build more homes is clear but equally there needs to be quality and a focus on delivering places to live, learn, work and play with a focus on health and wellbeing ; not as optional extras to be negotiated away.

Viability needs to encompass social and environmental components. The current focus on developer profits is necessary but only leg of a stool. Aspects of social viability that get lost include the need for social and affordable housing which is at its lowest build rates for years and for environmental viability the loss of quality green space and biodiversity. We do have the natural capital accounts to feed into this process now.

I hope that the government and MHCLG can respond to these concerns in the revised NPPF. In a climate where Brexit dominates much ministerial time and headspace I hope that we can recognise and value the positive aspects that a well managed and resourced planning system can deliver.

[4] I sue the word normal here to challenge the way many commentators call this extreme weather. It is not extreme for the UK now as we move into a new normal where extreme events become more common. In this way we need to factor such normality into our planning responses. Here climate change is a key consideration.